SecProbe.io

February 9, 2011
 Ron J. Copher  Senior Vice President and CFO  Glacier Bancorp, Inc.  49 Commons Loop  Kalispell, MT 59901
Re: Glacier Bancorp, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2009 Filed March 1, 2010 Forms 10-Q for the Quarterl y Periods Ended March 31, 2010,
June 30, 2010, and September 30, 2010
  File No. 000-18911

Dear Mr. Copher:
 We have reviewed your response letter da ted January 31, 2010 and have the following
comments.  In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
 Please respond to this letter within te n business days by providing the requested
information, including a draft of your proposed disclosures to be made in future filings, or by
advising us when you will provide the requested  response.  If you do not believe our comments
apply to your facts and circumstances or do not be lieve future revisions are appropriate, please
tell us why in your response.
 After reviewing the information you provide in response to these comments, including
the draft of your proposed disclosures, we may have additional comments.
            Form 10-Q for the Fiscal Qu arter Ended September 30, 2010

 Item 2. Management’s Discussion and Analys is of Financial Condition and Results of
Operations
 Additional Management’s Discussion and Analysis

Ron J. Copher
Glacier Bancorp, Inc.  February 9, 2011 Page 2

 Non-Performing Assets, page 42

1. We note your response to prior comment four  of our letter dated January 12, 2011 that
after a partial charge-off is made on an impair ed loan it could either be designated as non-
accrual or accrual.  In addition, we note that if  a loan is in the process of collection and
the loan is well-secured by collateral with suffi cient fair value to pay off the debt in full
you will resume the accrual of in terest on the loan.  It is not clear from this response
whether a partially charged-off impaired loan is returned to performing status or remains
as non-performing.  Please tell us and revise your disclosures in future filings beginning
with your 2010 Form 10-K to distinguish betw een when a partially charged-off impaired
loan will be designated as performing vers us when it would remain as non-performing.
Specifically, state for partially charged-off loans how you consider the delinquency status
of the loan in your accrual determination.
2. We note that your general allowance decreased from $123.17 million at December 31,
2009 to $115.64 million at September 30, 2010.  In addition, we note from your
disclosure on page 42 that the total non-accrual loans in the 1-4 family, home equity lines
of credit, consumer, and other categories  actually increased from $29.41 million at
December 31, 2009 to $30.99 million at Septembe r 30, 2010.  Please tell us and revise
your disclosure in future filings beginning with your 2010 Form 10-K to more clearly
bridge the gap between the decline in your cred it quality in the these loan portfolios with
the decrease in your general allowance for loan losses.

3. We note your earnings release dated Janua ry 27, 2011 on your website that states
unaudited net charge-offs and provision for loan losses for 2010 were $90.51 million and $84.69 million.  In addition, we note that net charge-offs for 2009 totaled $58.43 million.
Given the significant increase in net char ge-offs from 2009 to 2010 and the higher net
charge-offs than provision for loan losses in  2010, please tell us and provide enhanced
disclosures in future filings beginning w ith your 2010 Form 10-K, that bridge the gap
between observed changes in asset qualit y and resulting period end allowance and
recorded provision for loan losses.

Ron J. Copher
Glacier Bancorp, Inc.  February 9, 2011 Page 3

4. In addition, in the future pleas e file within the prescribed time limits a Form 8-K under
Item 2.02 - Results of Operations and Financial Condition when you make a public announcement or release regarding your results  of operations or fi nancial condition for a
completed quarterly or annual fiscal period.

5. We note from your response to prior comment five of our letter dated January 12, 2011
that you consider TDR (troubled debt restruct uring) loans as impaired loans and that at
least quarterly you perform an updated and co mprehensive assessment of the willingness
and capacity of the borrower(s) to timely and ultimately repay their total debt obligations.
Please tell us and revise future filings be ginning with your 2010 Form 10-K to disclose
whether the total debt obligati ons due from a single or rela ted party group of borrowers,
where at least one of the loans was is consid ered a TDR, is classified as impaired and
evaluated under the guid ance of ASC 310-10-35.

6. We note your response to prior comment six of our letter dated January 12, 2011 and also
note in your “Credit Quality Summary” tabular  disclosures in your news release dated
January 27, 2011 on your website that the categori es residential constr uction and land, lot
and other construction loans account for 61%  or $117.68 million of your total unaudited
non-accrual loans at December 31, 2010.  In  addition, we note these same categories
accounted for $58.73 million or 65% of your to tal unaudited net charge-offs for 2010.
Given the concentration of credit risk in thes e loan categories, pleas e tell us and provide
the following information in future filings  beginning with your 2010 Form 10-K related
to your residential construction and land, lot and other constr uction non-performing
loans:
a. General information about the type of  collateral securing these non-performing
loans and the borrower;
b. If there is a concentration of 5% or more for these loans in a bank subsidiary or
geographic location of the underlying collateral;
c. Status of the construction project or development; and
d. The appraisal method for these loans (i .e. “as-is” versus at completion).

7. We note from your response to prior comment  seven in our letter dated January 12, 2011
that 37% of your commercial real estate lo an dollar balances as of December 31, 2010
were based on an appraisal greater than twelve  months.  Please tell us and disclose in
future filings beginning with your 2010 Form 10-K the following:
a. How you determine whether to order a new appraisal or rely on your internal
evaluation. We note from your policy that at  least quarterly you review appraisals
or evaluations (new or updated) for your  collateral-dependent impaired loans.

Ron J. Copher
Glacier Bancorp, Inc.  February 9, 2011 Page 4

b. The specific procedures you perform and third-party evidence you rely upon to
update the valuation of the underlying co llateral with an a ppraisal more than
twelve months old.
c. In instances where current valuations of the underlying collateral  are not available
for an impaired loan, how you factor into your impairment analysis known
depreciation in the collatera l values of similar properties.  For example, if you
receive an updated appraisal on a similar pr operty that reflects deterioration in the
market value of that property; do you make adjustments to the collateral values of
other properties in the same area to reflect the market deterioratio n? If not, please
tell us why you don’t believe this would be relevant information to be considered
in your impairment analysis.

You may contact Lindsay McCord at 202- 551-3417 or me at 202-551-3423 if you have
any questions.
Sincerely,

Amit Pande Accounting Branch Chief